Personal Data Policy

1. Introduction

1.1. AEM Holdings Limited and its subsidiaries (“AEM” or as appropriate in the context, “we”, “us” or “our”) takes the responsibilities under the Singapore Personal Data Protection Act 2012 (“PDPA”) and other applicable data protection laws seriously.  

1.2. This Personal Data Policy (“Policy”) sets out:

• how we manage your Personal Data;
• the types of Personal Data we collect, use, disclose and/or retain;
• how we collect, use, disclose and/ or retain your Personal Data; and
• the purpose(s) for which we collect, use, disclose and/ or retain your Personal Data.

1.3 “Personal Data” refers to any data and/ or information about you, whether true or not, from which you can be identified by, either (a) from that data; or (b) from that data and other information to which we may have legitimate access to. Examples of Personal Data include but are not limited to your name, identification number, date of birth, gender, nationality, contact numbers, residential and/or mailing addresses, email address and any other information relating to yourself or any other individual.   

2. Consent

By voluntarily providing any Personal Data to us in the course of interacting with or transacting with us, calling or sending messages to us, accessing our websites and/ or submitting information to us via forms or other data collection means or processes:

• You signify that you have read, understood and agreed to our collection, use, disclosure and/ or retention of your Personal Data in the manner set forth in this Policy. 
• You thereby consent to the collection, use and/or disclosure of such Personal Data by us for the purpose for which such Personal Data was disclosed and/or for any reasonable purpose or for which you have been notified (which includes any the purposes set out in the section below), until and unless you notify us otherwise.
• Where you give us Personal Data about other individuals, you confirm that you are authorised to disclose and consent, on their behalf, to the use of such Personal Data for the purpose for which such Personal Data was disclosed and/or for any reasonable purpose or for which you have been notified (which includes any the purposes set out in the section below), until and unless you notify us otherwise.

3. Purposes

3.1. The Personal Data that you provide to us may be used for the following purposes (as may be appropriate or reasonable in the context of your interactions with us):

• To conduct due diligence/ background checks that are mandated by legislation or internal policies and practices of AEM.
• To evaluate and acquire products and services.
• To keep you updated on changes to the policies of AEM.
• To evaluate and to improve AEM’s products and services.
• To communicate with you (e.g., to respond to queries, complaints or comments on the products and services of AEM; to inform you of any developments to the products and services of AEM, the business of AEM and/or other corporate events or updates).
• To evaluate applications for employment/ job positions within AEM and to manage the employment relationship.
• For security clearance/ entry access into the premises of AEM.
• To comply with applicable laws and regulations.
• To perform a contract or other legal obligation. 
• For purposes that are ancillary to or in furtherance of the above purposes.

The purposes for which we may/will collect, use, disclose or process your Personal Data depend on the circumstances at hand and, as such, may not appear above.  

3.2. In order to smoothly conduct our business operations or to fulfil our obligations to you, we may disclose your Personal Data to third parties, whether located within or outside of Singapore, for one or more of the above purposes or as notified to you. Without limiting the generality of the foregoing, such third parties include:

• Group Companies: our associated or affiliated organisations or related corporations, or any member of the AEM Group;
• Data Intermediaries: our agents, contractors or third party service providers that process or will be processing your Personal Data on our behalf including but not limited to those which provide administrative or other services to us such as telecommunication companies, information technology companies, data centres, maintenance service providers, e-mail messaging services service providers, delivery service provider, handling of payment transactions service providers and marketing service providers; and/ or
• Third parties who have a legitimate interest: our professional advisers such as auditors and lawyers, our insurers, or potential acquirers of any Group Company or business. 

In situations where we transfer your Personal Data overseas, we will take appropriate steps to ensure that the overseas recipient has in place appropriate levels of protection necessary to maintain the security and integrity of your Personal Data in accordance with any applicable laws.

4. Retention of Personal Data

Your Personal Data in our possession or under our control will be destroyed (or expunged from our systems) and/or anonymized as soon as it is reasonable to assume that:

• the purpose for which that Personal Data was collected is no longer being served by the retention of such Personal Data; and
• retention is no longer necessary for any other business or legal purposes. 

5. Accuracy of Personal Data

We will endeavour to ensure that your Personal Data remains accurate particularly if such Personal Data is to be used to make a decision that affects you or any other individual. For this reason, you should keep us informed when there are any changes to your Personal Data by contacting us directly or by responding promptly to any request from us to verify the accuracy of your Personal Data. 

6. Contact Us

6.1. You may contact us:

• to request to access and/or correct your Personal Data in our possession; 
• to withdraw your consent to the continued use and/or disclosure of any Personal Data for all or any particular purpose; or
• if you have any questions or complaints regarding about how we are handling your Personal Data.

6.2. You may contact us either by email or by post to AEM’s designated Data Protection Officer at:

6.3. When contacting us, please state the purpose for which you are contacting us, your name and an email address or mailing address at which we can contact you, and the nature of our relationship with you.

6.4. AEM will endeavour to respond to you as soon as possible within 30 days.  If we are unable to do so for any reason, we will inform you accordingly and the time by which we will respond to the request.

7. Changes to this Policy

AEM may review and amend this Policy at any time and from time to time.  Should any revision(s) be made to this Policy, updates will be published on our public site (www.aem.com.sg).  We recommend that you review this Policy from time to time so you are aware of any changes or updates to the Policy. 

Effective Date: 1^st October 2021