WIRANA PTE LTD PRIVACY POLICY

1. INTRODUCTION

This Privacy Policy ("Policy") sets out the basis upon which Wirana Pte Ltd ("we", "us", or "our") may collect, use, disclose or otherwise process personal data in accordance with the Personal Data Protection Act 2012 ("PDPA"). This 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 our purposes.

Wirana Pte Ltd is a trading company specializing in the purchase of ships at the end of their life cycle and selling them to scrap vendors. As a business-to-business (B2B) company, we primarily collect personal data from our employees, job applicants, and visitors to our premises or website.

2. PERSONAL DATA

As used in this 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.

Depending on your relationship with us, personal data which we may collect includes, without limitation:

• a) All Individuals:
  • Name or alias, gender, NRIC/FIN or passport number, date of birth, nationality, and race
  • Residential address, mobile numbers, email address
  • Photographs and other information collected when visiting our premises
  • Information provided to us through customer service channels, surveys, or events


• b) Job Applicants:
  • Educational and professional qualifications
  • Employment history and references
  • Curriculum vitae, resume, or cover letter
  • Information provided during interviews or assessments
• Employees: Additional personal data as outlined in our Employee Data Protection Notice.
• Website Visitors:
  • IP address
  • Browser type and version
  • Device information
  • Log data and browsing behavior

3. COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA

3.1 Collection Methods

We generally collect personal data in the following ways:

• a) When you submit forms or applications to us;
• b) When you submit queries, requests, or feedback to us;
• c) When you interact with our staff, including customer service officers and relationship managers;
• d) When you respond to our promotions, events, or surveys;
• e) When you visit our premises or attend our events;
• f) When you visit or use our website
• g) When you enter into any agreement or provide other documentation or information in respect of your interactions with us; or
• h) When you submit your personal data to us for any other reason.

3.2 Purposes for Collection, Use and Disclosure

• Business Operations:
  • a) Responding to and processing your inquiries and requests;
  • b) Managing our administrative and business operations and complying with internal policies and procedures;
  • c) Facilitating business asset transactions (which may extend to any merger, acquisition or asset sale);
  • d) Matching any personal data held by us concerning you for any of the purposes listed herein;
  • e) Preventing, detecting and investigating crime, including fraud and money-laundering, and analyzing and managing commercial risks;
  • f) Managing the safety and security of our premises and services;
  • g) Project management and reporting to management;
  • h) Organizing events, corporate social responsibility projects, and other industry initiatives.

• Job Applicants and Employment
  • a) Processing your application (including pre-recruitment checks);
  • b) Providing or obtaining employee references or other references where relevant for recruitment purposes;
  • c) Collecting information about your suitability for the position applied for;;
  • d) Organizing events, corporate social responsibility projects, and other industry initiatives.
  • e) Assessing your performance;
  • f) Administering benefits and payroll processing;
  • g) Providing you with tools to facilitate or as required for you to do your job;
  • h) Communicating with you to comply with our policies and processes, including for business continuity purposes.

Legal and Regulatory Compliance

• a) 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;
• b) Managing and preparing reports on incidents and accidents;
• c) Conducting audit checks, due diligence, and risk assessments;
• d) Complying with all applicable laws, regulations, rules, directives, orders, instructions, and requests from any local or foreign authorities.

Additional Purposes

• a) Conducting analysis of customer behavior, preferences, and market trends;
• b) Developing, improving, and providing products and services to meet your needs;
• c) Processing and administering benefits;
• d) Processing your payment instructions, direct debit facilities and/or credit facilities;
• e) Managing our infrastructure and business operations and complying with internal policies and procedures.

3.3 Disclosure of Personal Data

Subject to the provisions of any applicable law, your personal data may be disclosed to the following entities, for the purposes listed above (where applicable):

• a) Our related corporations (including Wirana affiliates and subsidiaries);
• b) Companies providing services related to insurance, business consulting, auditing, and corporate governance to our organization;
• c) Agents, contractors, or third-party service providers who provide operational services to us, such as IT, telecommunications, marketing, administration, data processing, storage, or archival;
• d) Any business partner, investor, assignee, or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition, or asset sale);
• e) Our professional advisers such as consultants, auditors, and lawyers;
• f) Foreign and local government authorities, regulatory and/or statutory bodies, industry associations, courts, alternative dispute resolution tribunals, and/or public agencies for compliance with applicable laws, rules, guidelines, and regulations, codes of practice, directives, orders, instructions, and requests issued by any such party;
• g) Any other party to whom you authorize us to disclose your personal data.

4. CONSENT AND WITHDRAWAL OF CONSENT

4.1 Consent

By providing your personal data to us, you consent to our collection, use, and disclosure of your personal data for the purposes set out in this Policy. If you provide personal data of any third party to us, you represent and warrant that you have obtained the necessary consent from that third party to share and transfer his/her personal data to us, and for us to collect, use, and disclose such personal data for the purposes set out in this Policy.

4.2 Withdrawal of Consent

You may withdraw your consent to our continued use, disclosure, storing, and/or processing of your personal data by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.

Please note that withdrawing consent does not affect our right to continue to collect, use, and disclose personal data where such collection, use, and disclosure without consent is permitted or required under applicable laws. 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 thirty (30) business days of receiving it.

In exceptional circumstances, we may refuse to accede to your request to withdraw consent, if such withdrawal would result in our inability to continue providing our products or services to you (e.g., if the

personal data is required for us to fulfill our legal or contractual obligations to you).

5. DEEMED CONSENT BY NOTIFICATION

5.1 We may collect or use your personal data, or disclose existing personal data for secondary purposes that differ from the primary purpose which it had originally collected for pursuant to Sections 3.1 and 3.2. If Wirana Pte Ltd intends to rely on deemed consent by notification for such secondary purposes, we will notify you of the proposed collection, use, or disclosure of your personal data through appropriate modes of communication.

5.2 In particular, we may rely on deemed consent by notification to collect, use, or disclose your personal data for the following purposes:

• a) To inform you about our latest developments, initiatives, and promotions;
• b) To send you technical alerts, updates, security notifications, and administrative communications;
• c) For our business development purposes, such as generating insights, producing analytics, or enhancing our products and services.
• d) For our business development purposes, such as generating insights, producing analytics, or enhancing our products and services.

5.3 Before relying on deemed consent by notification, Wirana Pte Ltd will assess and determine that the collection, use, and disclosure of the personal data will not likely have an adverse effect on you.

5.4 You will be given a reasonable period to inform us if you wish to opt-out of the collection, use, and disclosure of your personal data for such purposes.

5.5 After the lapse of the opt-out period, you may notify us that you no longer wish to consent to the purposes for which your consent was deemed by notification by withdrawing your consent for the collection, use, or disclosure of your personal data in relation to those purposes.

6. RELIANCE ON THE LEGITIMATE INTERESTS EXCEPTION

6.1 In compliance with the PDPA, we may collect, use, or disclose your personal data without your consent for the legitimate interests of Wirana Pte Ltd or another person. In relying on the legitimate interests exception of the PDPA, Wirana Pte Ltd will assess the likely adverse effects on the individual and determine that the legitimate interests outweigh any adverse effect.

6.2 In line with the legitimate interests' exception, we will collect, use, or disclose your personal data for the following purposes:

• Fraud detection and prevention;
• Detection and prevention of misuse of services;
• Network analysis to prevent fraud and financial crime;
• Collection and use of personal data on company-issued devices to prevent data loss;
• Managing and monitoring of workplace safety;
• Ensuring network and information security.

6.3 The purposes listed in the above clause 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.

7. ACCESS TO AND CORRECTION OF PERSONAL DATA

7.1 If you wish to make an access request for access to a copy of your personal data which we hold or information about the ways in which we use or disclose your personal data, or a correction request to correct or update any of your personal data which we hold, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.

7.2 Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.

7.3 We will respond to your request as soon as reasonably possible. In general, our response will be within thirty (30) business days. Should we not be able to respond to your access request within thirty (30) days after receiving your access 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).

7.4 Please note that depending on the request that is being made, we will only need to provide you with access to the personal data contained in the documents requested, and not to the entire documents themselves. In those cases, it may be appropriate for us to simply provide you with confirmation of the personal data that our organization has on record, if the record of your personal data forms a negligible part of the document.

8. PROTECTION OF PERSONAL DATA

8.1 To safeguard your personal data from unauthorized access, collection, use, disclosure, copying, modification, disposal, or similar risks, we have introduced appropriate administrative, physical, and technical measures such as:

• Minimized collection of personal data;
• Authentication and access controls (such as good password practices, need-to-basis for data disclosure, etc.);
• Encryption of data;
• Data anonymization, where applicable;
• Up-to-date antivirus protection;
• Regular patching of operating system and other software;
• Secure erase storage media in devices before disposal;
• Web security measures against risks;
• Usage of one-time password (OTP)/2-factor authentication (2FA)/multi-factor authentication (MFA) to secure access;
• Security review and testing performed regularly;
• Regular backup of data;
• Restricted physical access to servers and data storage areas;
• Confidentiality clauses in our employment contracts and service provider agreements.

9. 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 Protection Officer in writing or via email at the contact details provided below.

10. RETENTION OF PERSONAL DATA

• We may retain your personal data for as long as it is necessary to fulfill the purposes for which they were collected, or as required or permitted by applicable laws.
• 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 purposes for which the personal data were collected, and are no longer necessary for legal or business purposes.

11. TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE

• We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.
• Before transferring personal data outside Singapore, we will take appropriate steps to ascertain whether, and ensure that, the recipient of the personal data is bound by legally enforceable obligations to provide to the transferred personal data a standard of protection that is at least comparable to the protection under the PDPA.

12. DATA BREACH NOTIFICATION

12.1 In the event of a data breach that is likely to result in significant harm or impact to you to whom any personal data affected by a data breach relates or where the data breach is of a significant scale, we will notify the PDPC and affected individuals of the data breach as required under the PDPA.

13. DATA PROTECTION OFFICER

13.1 You may contact our Data Protection Officer if you have any inquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:
Email Address: dpo@wirana.com.sg

14. COOKIES POLICY

14.1 Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

14.2 A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is tansferred to your computer's hard drive.

14.3 We use the following cookies:

• Strictly necessary cookies: These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website.
• Analytical/performance cookies: They allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies: These are used to recognize you when you return to our website. This enables us to personalize our content for you and remember your preferences.

14.4 You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

15. EFFECT OF POLICY AND CHANGES TO POLICY

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

15.2 We may revise this 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 Policy was last updated. Your continued use of our services constitutes your acknowledgment and acceptance of such changes.

Effective date: 01/04/2025
Last updated: 01/04/2025