Amerex Singapore Privacy and Data Protection Policy

1. Introduction

The purpose of this document (the “Policy”) is to inform you of how we, Amerex Petroleum #2 Singapore Pte Ltd (hereinafter referred to as “Amerex”, “we”, “us”, or “our”) collect, use or disclose your personal data in accordance with the Personal Data Protection Act 2012 of Singapore (the “PDPA”) and the EU General Data Protection Regulation (the “GDPR”).
We ask and require that each of the following parties / persons abide by this DPP:

a) All our employees
b) All volunteers and trainees
c) Third parties (including third party partners, service providers, or affiliates) whom we work with and who have agreed to abide by this DPP.

We may from time to time update this Policy to ensure that it is in line with any future developments in the business climate and/or changes in the regulatory requirements. You agree to be bound by the prevailing terms of the Policy as updated from time to time on our website and/or electric mail notification. You will only be notified of such changes if it relates to material changes in the Policy. If you do not wish to comply with the updates to the Policy, you may not be able to use our website or our services.

2. Personal Data

The personal data that we collect is (the “Personal Data”):

• • Data collected directly from you. This may be collected through our website, through our third party service providers and/or partners, through the completion of our forms when you engage our services, and over the phone or by email. These data consists of personal information that can be used to identify an individual, like your name, gender, country of residence, date of birth, or identification number, and includes, but is not limited to:
  • Contact information, such as mailing address, or email address;
    • Information we receive from any of our forms that you fill;
    • Information we receive from your submission of a job application, or any comment, question or feedback to us; and
    • Other personal data you choose to provide.
  • Data collected by automated means. When you use our website, we may automatically collect information from your devices. These data may include:
    • Server log information: We may collect server log information when you use our website, which may include (but is not limited to) the date and time of visits, the pages viewed, your IP address, time spent at our website, the websites you visit just before and just after our website, the domains you come from;
    • Device information: We may collect information about the computer or mobile device you use to access our website, including the hardware model, operating system and version, the web browser you use, and other device identifiers;
  • Information collected by cookies:
    • We and/or our service providers may use cookies to collect information when you interact with our website.
    • Cookies are small data files that are stored on your device when you visit a website, which enable us to collect information about your device identifiers, IP address, web browsers used to access the website, pages or features viewed, time spent on pages, mobile app performance and links clicked.

3. Collection of Personal Data

Generally, we will collect your personal data when you:

1. 1. 1. interact with our staff, including customer service officers and other representatives via telephone calls, letters and email;
      2. are contacted by, and respond to, our customer service officers and other third party service providers and/or partners;
      3. receive your personal data from our third-party intermediary and/or partners to provide you with our services;
      4. complete our forms prior to engaging our services;
      5. make payment or provide details to facilitate payment;
      6. submit any form to enquire, question, feedback and/or complain about our business or contact us on our website;
      7. request that we contact you, be included in an email or other mailing list; or when you respond to our request for additional personal data, and other initiatives;
      8. indicate that you want information emailed from us;
      9. browse our website;
      10. submit your personal data to us for any other reasons; and
      11. apply for a job through our website.

You have no obligation to provide any Personal Data requested by us. However, depending on the circumstances, it may be the case that if you do not provide the requested personal data, we may not be able to assist you or you may not be able to use our website, services which we may be providing, or otherwise interact or engage with us, where these depend on the collection, use or disclosure of your personal data. (See also 11.B below)

4. Purpose of collection, use and disclosure of personal data

We will collect, use or disclose your personal data that we have collected from you for the following purposes (collectively referred to as the “Purposes”):-

1. 1. To provide our services including arranging and executing trades on your behalf;
   2. to verify your identity and accredited investor status, and perform due diligence on you should you use our services, including but not limited to assessing any risks against money laundering or terrorist financing;
   3. for promotional and publicity purposes, including telling you about our services or other related products and services offered by us;
   4. to respond to your customer service enquiries, feedback, suggestions, complaints and comments;
   5. to manage services, and our administrative and business operations;
   6. the day-to-day operation of services;
   7. to understand our customers and their needs and improve our services;
   8. to investigate suspicious activities or acts of fraud, misconduct, unlawful actions or omissions;
   9. record keeping and complying with internal policies and procedures;
   10. if you apply for a job with us, to administer and process any request for information or job application. We may disclose your information to external parties, such as recruitment companies, where it is clearly stated in the job advertisement;
   11. if you have indicated that you want information emailed from us, the name and/or company name and email address will be stored by us to be used to send relevant information to you via our email system. You can cancel these messages whenever you want by unsubscribing via a link in the email or by contacting us below;
   12. responding to online inquiries, and analyzing our Website traffic;
   13. investigating or preventing illegal activities or suspected fraud, or to enforce or apply our rights and property;
   14. circumstances may arise where, whether for strategic or other business reasons, we decide to sell, buy or merge. Such a transaction may involve the disclosure of personal information to prospective or actual purchasers, or the receipt of it from sellers;
   15. disclose your personal data to third parties in order to comply with applicable laws, regulations and industry requirements. This includes disclosures to legal, regulatory, governmental, tax and law enforcement authorities. In addition, we may disclose information in order to investigate, prevent, or take action regarding illegal activities or suspected fraud, or to enforce or apply our agreements;
   16. aggregating statistics about your visit to our website to help us improve the performance of our Website;

We collect, use and disclose personal information only for the Purposes. We will request your consent before we use or disclose your information for any other purposes. In addition, unless specifically described above, consent may be obtained in any legally sufficient method.

5. Disclosure of Personal Data

We may also be disclosing Personal Data you have provided to us to third party service providers (the “Third Party Service Providers”) who provide necessary services to us, such as service providers and data processors working on our behalf, for the following reasons:

• • to facilitate the provision of our services by us to you;
  • for them to provide our services on our behalf;
  • for them to perform other services ancillary to our services;
  • for them to assist us in performing due diligence on you; or
  • to comply with applicable laws, regulations and industry requirements. This includes disclosures to legal, regulatory, governmental, tax and law enforcement authorities.

6. Consent

• • By using our website, or services or when you otherwise engage or interact with us, you are deemed to have agreed to, consented to, and authorized the collection, use, disclosure and/or transfer of your personal data by us in accordance with this Policy, as well as the collection and use of your personal data by Third Party Service Providers to which we disclose or transfer your personal data to, for any one or more of the Purposes.
  • Where Personal Data is collected by our employees through our forms for verifying your identity and performing due diligence, the forms shall highlight the purpose for which the data is collected, and shall obtain consent from the individual for the same.
  • You may exercise your right to withdraw your consent and opt-out of our collection, use and/or disclosure of your personal data in our possession or under our control at any time, or update your personal data stored with us (your “Rights”), by submitting your request in the manner prescribed in the Withdrawal Policy, and/or to the contact details set out in Section 11 below. In such a case, we will process your request within 28 days of receipt of such a request for withdrawal of consent being made, and will thereafter refrain from collecting, using and/or disclosing your personal data in the manner stated in your request. Should more time be required to process your request, we shall promptly inform you of the timeframe by which the withdrawal shall take effect. A withdrawal of your consent to our collection, use and/or disclosure of your personal data may however mean that we are unable to provide you with our services or access to our Website.

7. Accuracy

You warrant and represent to us that the personal data that you disclose to us is accurate and complete. We will use our reasonable efforts to maintain the personal data accurately and protect the personal data against manipulation and errors. To help us maintain the accuracy of the personal data, we encourage you to inform us when there are changes to the personal data which you have provided to us.

8. Security

We value your trust in providing us your personal data, thus we are striving to use commercially acceptable means of protecting it. We will implement security features to ensure that your personal data is adequately protected and secured and to prevent the unauthorized release of or access to the personal data. We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include, but are not limited to, internal reviews of our data collection, storage and processing practices and security measures, including appropriate encryption and physical security measures to guard against unauthorized access to systems where we store or use to collect personal data. But remember that no method of transmission over the internet, or method of electronic storage is 100% secure and reliable, and we cannot guarantee its absolute security.

We restrict access to personal information to our employees, contractors and agents who need to know that information in order to process it on our behalf. These individuals are bound by confidentiality obligations and may be subject to discipline if they fail to meet these obligations.

9. Breach notification

In the case of data breaches, we will inform the relevant authorities as soon as possible of any data breaches that might cause public concern or where there is a risk of harm to a group of affected individual.
If the breach is a high-risk breach, then Amerex will also endeavour to immediately inform the individuals who are impacted.

10. Hyperlinks and third-party sites

Our Website may contain links to other third party websites that may collect personal information about you, including through cookies or other technologies. If you link to another website, you will leave our Website and this Policy will not apply to your use of and activity on those other websites. You should consult these other websites’ privacy policies as we have no control over them and are not responsible for any information that is submitted to or collected by these third parties.

11. Rights over Personal Data

A. You have certain rights under the PDPA in relation to the personal data we hold about you. These rights are detailed below.

• • Access: You have the right to request to have access to the personal data that is in our possession or under our control, as well as the information about the ways in which that personal data has been disclosed by us within a year before the date of your request. Prior to responding to any request by you to access your personal data, we will have the right to exercise due diligence and adopt appropriate measures to verify your identity. In the event where a third party is making an access request on behalf of you, please ensure that such third party furnishes to us satisfactory documentation evidencing that he or she has the legal authority to validly act on your behalf. We will endeavour to respond to an access request as soon as reasonably possible, or within 30 days after receiving the request, whichever is the earlier. In the event we are unable to provide you with the required documents within 30 days from the date of your request, we will inform you in writing of the same. Where permitted by law, we reserve the right to charge a reasonable administrative fee for this service.
  • Erasure: You may request for us to erase any personal data we hold about you at any time. We will respond to deletion requests within 28 days. Do note however that if you choose to request for us to erase any of our records of your personal data at any time, you may not be entitled to use our Website or our services or any part thereof. In the absence of any request by you to erase our records of your personal data, we will cease to retain any documents containing your personal data, or remove the means by which the personal data can be associated with you, as soon as it is reasonable to assume that the Purpose for which that personal data was collected is no longer served by retention of the personal data, and retention is no longer necessary for legal or business purposes.
  • Correction: You have the right to correct any personal data held about you that is inaccurate.
  • Feedback and complaints: Please let us know if you have any concerns, feedback or complaints relating to the personal data or our Policy.
  • Withdrawal Policy: Please be notified that you may opt-out of our collection process at any time by contacting our Data Protection Controller at the contact details specified below. We will process any opt-out requests within 28 days. Do note however that if you choose to withdraw your consent for us to collect, use and disclose your personal data, you may not be entitled to use our Website or any part thereof.

However, this does not include any data we are obliged to keep for administrative, legal, or security purposes.

1. You may submit your request in the following manner:
   “I withdraw my consent to the use and disclosure of my personal data as follows:-
   1. Verifying my identity and conducting due diligence
      ( This means we will be unable to provide you with our services)
   2. Managing your services, and for administrative and business operations
      ( This means we will be unable to provide you with our services)
   3. Receiving information about your company’s services, via the following channels:
      i. Email
      ii. Text Message
      iii. Phone Call
   4. Market research and improvement of your services

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Contact Details: If you wish to exercise any of your Rights under Section 6, please contact us through our Data Protection Controller (below) indicating your name and country of residence in your correspondences with us:

Amerex Data Protection Controller

Name:	Philip Jump
Email:	philjump@amerex.com.sg
Telephone:	+65 6416 4938
Address:	123 Penang Road #07-12 Regency House Singapore 238465

In addition to the above, where your information is protected under the GDPR, you have the following additional rights (“Additional Rights”):

• Information: You have the right to be informed. This means that anyone processing your personal data must make clear what they are processing, why, and who else the data may be passed to.
• Restricted processing: You have the right to ask for a temporary halt to processing of your personal data, such as in the case where a dispute or legal case has to be concluded, or the data is being corrected.
• Data portability: You have a right to ask for any data supplied directly to the Data Officer to be provided in a structured, commonly used, and machine-readable format. You further have a right right to request that we transfer such data to another organisation.
• Objection: You have the right to object to further processing of your data which is inconsistent with the primary purpose for which it was collected, including profiling, automation, and direct marketing.
• Automated decision making and profiling: You have the right not to be subject to a decision based solely on automated processing.
  If you wish to exercise any of your Additional Rights, please contact us through the Contact Details above.

12. Changes to This Policy

We may update our Policy from time to time. Thus, you are advised to review this page periodically for any changes. We will notify you of any changes by posting the new Policy on this page. These changes are effective immediately after they are posted on this page.