This Data Privacy Policy (“Privacy Policy”) sets out the basis in which Asure Pro Pte Ltd (“AGPL”, “we”, “us”, or “our”) may collect, use, disclose or otherwise process your personal data in accordance with the Personal Data privacy Act (“PDPA”) of Singapore. This Privacy Policy applies to personal data in our possession or under our control, including personal data in the possession of organizations which we have engaged to collect, use, disclose or process personal data for such purposes which have been notified. This Privacy Policy is read in conjunction with, and is deemed incorporated by reference, to be part of our Terms and Conditions of Use.

1. Personal Data

1.1. As used in this Privacy Policy, “personal data” means data, whether true or not, about an individual who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access.

1.2. Other terms used in this Privacy Policy shall have the meanings given to them in our Terms of Use or the PDPA (where the context so permits).

1.3. Depending on the nature of your interaction with us, on the Sites or through any Service we provide, the type of information that we may collect includes:

• Personal data and contact information. We may collect information with personal identifiers including your name and identification information such as your NRIC number, contact information such as your address, email address or telephone number, nationality, gender, date of birth, marital status, photographs and other audio-visual information.

• Employment details. We may collect information from your CV in relation to your occupation and other positions held, employment history, salary, and/or benefits or education history.

• Financial information. We may collect financial information such as credit card numbers, debit card numbers or bank account information and details of any other information that allows us to transact with you and/or provide you with our Services.

• Device and Technical Information. We collect device-specific and other technical information about your mobile or computer device such as the hardware model, operating system version, browser type and version, Internet Protocol (IP) address, advertising identifier, unique application identifiers, unique device identifiers, browser type, language, wireless network, and mobile network information (including the mobile phone number).

• Other Anonymized Data. We may collect information that is not associated with or linked to your personal data and cannot be used to identify you or any other individuals (“Anonymized Data”).

1.4. Most information will be collected when you use the Sites or when you use the Services. However, we may also use various technologies on the Sites which may lead to information being collected automatically by us or from other sources such as advertising, sub-contractors in technical and payment services, analytics providers, search information providers and mailing lists. This information does not generally, but may, contain your personal data.

In particular, information is likely to be collected as follows:

• Web beacons. Web beacons (also known as “clear gifs” and “pixel tags”) are small transparent graphic images that are often used in conjunction with cookies in order to further personalize the Service for our users, collect a limited set of information about our visitors, and advertise to our users.

• Web analytics. Web analytics is the method for collecting and assessing the behavior of users on the Sites. This includes the analysis of traffic patterns in order, for example, to determine the frequency of visits to certain parts of a website or mobile application, or to find out what information and services the users are most interested in. We may also use web beacons in email communications in order to understand the behavior of our users, such as whether an email has been opened or acted upon.

• Cookies. We use cookies on the Sites, which are small text files that a website stores on your PC, telephone or any other device with information on your navigation on the Sites, whose principal objective is to improve your experience on the Sites, track use of the Sites and to provide us subsequently with aggregated information of these activities for statistical purposes. By default, cookies are enabled on web browsers but if you prefer, you may disable the use of cookies in your browser and delete the cookies saved in your browser associated with the Sites.

2. Collection, use and disclosure of personal data

2.1. As there are many circumstances in which we may collect information, we will endeavour to ensure that you are always aware of the information being collected, in particular by third parties. We generally do not collect your personal data unless

• it is provided to us voluntarily by you directly or via a third party who has been duly authorized by you to disclose your personal data to us (your “authorized representative”, for example Facebook or any other non AGPL digital platform) after (a) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (b) you (or your authorised representative) have provided consent to the collection and usage of your personal data for those purposes, or

• collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).

2.2. We may collect and use your personal data for any or all of the following purposes:

• performing obligations in the course of or in connection with our provision of the Services requested by you;
• verifying your identity;

• responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;

• detecting usage patterns;

• troubleshooting crashes associated with specific hardware and software used to access the Sites and Services;
• analysing trends;

• administering the sites;

• tracking user movements; and

• gathering broad demographic information for aggregate use of the Services;

• processing payment or credit transactions;

• sending you marketing information about the Services on behalf of ourselves and through our sponsors or other third-party service providers, including notifying you of advertisements, marketing events and other promotions; complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;

• any other purposes for which you have provided the information;

• transmitting to any unaffiliated third parties including our third-party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and

• any other incidental business purposes related to or in connection with the above.

2.3. Your personal data may also be anonymised for use by AGPL and its affiliates for other purposes.

2.4. It may be necessary for us to disclose your personal data to our affiliates or to third parties in a manner compliant with the PDPA in order to carry out the purposes set out above. We may disclose or share personal data with such parties who provide necessary services to us, such as for processing activities like verification, website hosting, data analytics and payment processing. We may disclose your personal data in the following circumstances:

• where such disclosure is required for performing obligations in the course of or in connection with our provision of the Services requested by you;

• third party online payment processing companies (e.g. Stripe) who will process your payments so that you can use the Services and/or make any related purchases;

• our consultants and professional advisers (e.g. accounting firms, audit firms, law firms and/or other professional advisory firms) who are maintaining our records in accordance with legal requirements;

• governmental, regulatory or law enforcement bodies who have a legal right to demand for your personal data, in response to a legal request such as a court order, to investigate or report an illegal activity, or to enforce our rights or defend claims;

• our affiliated or related companies and/or third parties to whom we may sell, divest, transfer, assign, share or otherwise engage in a transaction that involves, some or all of the our assets (which may include your personal data), in the course of a corporate divestiture, corporate restructuring, merger, acquisition, joint venture, bankruptcy, dissolution, reorganization, or any other similar transaction or proceeding; or

• third party service providers, agents and other organisations we have engaged to perform any of the functions listed in clause 2.2 above for us.

2.5. We do not sell, rent, license or otherwise disclose your personal data to third parties. We are careful in our selection of third-party service providers, and when we disclose your personal data to such parties, we shall require them to ensure that they are bound by obligations of data privacy (pursuant to contracts and/or applicable laws) similar to the obligations as set out in the PDPA.

2.6. We may also disclose aggregated information that is Anonymised Data about our users, including but not limited to the total number of our users and their overall demographics.

2.7. The Sites may have the functionalities to allow you to share personal data with other third parties such as other users of the Sites. You are responsible for your choice(s) and are deemed to have provided consent for any sharing of your personal data in the manner provided by the Sites. Please do not post or upload personal data to the Sites that you would not want to be publicly available.

2.8. The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).

3. Transfers of Personal Data Outside of Singapore

Pursuant to the purposes and activities as set out herein, it may be necessary for us to transfer your personal data out of Singapore for storage, processing and use by AGPL, its affiliates or any AGPL Sponsors (as defined in the Terms and Conditions of Use). You hereby agree and consent to the aforesaid transfer, on the understanding that the recipients of such personal data are also subject to applicable laws or contractual obligations similar to the obligations as set out in the PDPA.

4. Withdrawing your consent

4.1. The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Privacy Officer at the contact details provided in clause 10.1 below.

4.2. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it.

4.3. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 10.1 below.

4.4. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.

5. Access to and Correction of Personal Data

5.1. You may request access or make corrections to the personal data which we hold about you. You may also request information about the ways in which we use, process or disclose your personal data. Please submit your request in writing or via email to our Data privacy Officer at the contact details provided in clause 10.1 below.

5.2. We may charge a reasonable fee for processing your request for access. If so, we will inform you of the fee before processing your request.

5.3. We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).

6. Protection of Personal Data

6.1. We take all appropriate precautions to safeguard your personal data from unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks. Examples of measures we have implemented include encryption, privacy filters and up-to-date antivirus software to protect and secure all storage and transmission of your personal data.

6.2. You should be aware, however, that no method of transmission over the Internet and no electronic storage is completely secure. You understand that any message or information that you send, transmit or upload to the Sites may be read or intercepted by others, even if there is a special notice that a particular transmission is encrypted. While security cannot be guaranteed, we strive to protect the security of your personal data by constantly reviewing and enhancing our security measures. However, we cannot accept responsibility for misuse or loss of, or unauthorized access to your personal data.

7. Disclaimer

To the fullest extent permitted by law, we shall not be liable in any event for any special, exemplary, punitive, indirect, incidental or consequences of damages of any kind or for any loss of reputation or goodwill, whether based in contract, tort (including negligence), equity, strict liability, statute or otherwise, suffered as a result of unauthorized or unintended use, access or disclosure of your personal data.

8. Accuracy of Personal Data

We generally rely on personal data provided by you (or your authorized representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Privacy Officer in writing or via email at the contact details provided in clause 10.1 below.

9. Retention of Personal Data

9.1. We may retain your personal data for as long as it is necessary to fulfil the purposes for which it was collected, or as required or permitted by applicable laws.

9.2. We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.

10. Data Privacy Officer

10.1. You may contact our Data Privacy Officer if you have any complaints, enquiries or feedback on this Privacy Policy, your personal data as registered with us, or in relation to our use, retention, disclosure or transfer of your personal data, or if you wish to make any request, in the following manner:

Attn: Asure Pro Data Privacy Officer
Email: executive@asure.group

10.2. All requests for correction or for access to your personal data must be in writing. We will endeavor to respond to your request within 30 days, and if that is not possible, we will inform you of the time by which we will respond to you.

10.3. All complaints will be evaluated by AGPL in a timely manner. After AGPL has completed its evaluation, our Data privacy Officer (or duly appointed representative) will respond to the person who submitted the complaint or feedback, with the results of the evaluation.

10.4. We may be prevented by law from complying with any request that you make. We may also decline any request that you may make if the law permits us to do so.

11. Effect of Privacy Policy and changes to the Privacy Policy

11.1. This Privacy Policy applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.

11.2. We may revise this Privacy Policy from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Privacy Policy was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.

12. Governing Law

The terms and conditions of this Privacy Policy are governed by the laws of the Republic of Singapore. In the event of any disputes arising from this Privacy Policy, you must first contact our Data Privacy Officer regarding your concern and use your best endeavors to amicably settle any dispute in good faith. We on our part will also use our best endeavors to amicably settle your concerns in good faith. However, if no amicable resolution is reached within 30 days, you agree to submit to the exclusive jurisdiction of the Courts of the Republic of Singapore.