DATA PROTECTION NOTICE FOR CUSTOMERS


This Data Protection Notice (“Notice”) sets out the basis which TRAXX Motor Company Pte
Ltd (“we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of our
customers in accordance with the Personal Data Protection Act (“PDPA”). This Notice applies
to personal data in our possession or under our control, including personal data in the
possession of organisations which we have engaged to collect, use, disclose or process
personal data for our purposes.


PERSONAL DATA

  1. As used in this Notice:
    “customer” means an individual who (a) has contacted us through any means to find
    out more about any goods or services we provide, or (b) may, or has, entered into a
    contract with us for the supply of any goods or services by us; and
    “personal data” means data, whether true or not, about a customer 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.

  2. Depending on the nature of your interaction with us, some examples of personal data
    which we may collect from you include name, residential address, email address and
    telephone number.

  3. Other terms used in this Notice shall have the meanings given to them in the PDPA
    (where the context so permits).

    COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
  4. We generally do not collect your personal data unless (a) it is provided to us voluntarily
    by you directly or via a third party who has been duly authorised by you to disclose your
    personal data to us (your “authorised representative”) after (i) you (or your authorised
    representative) have been notified of the purposes for which the data is collected, and
    (ii) you (or your authorised representative) have provided written consent to the
    collection and usage of your personal data for those purposes, or (b) 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).

  5. We may collect and use your personal data for any or all of the following purposes:
    (a) performing obligations in the course of or in connection with our provision of the
    goods and/or services requested by you;
    (b) responding to, handling, and processing queries, requests, applications,
    complaints, and feedback from you;
    (c) managing your relationship with us; and
    (d) processing payment or credit transactions.

  6. We may disclose your personal data:
    (a) where such disclosure is required for performing obligations in the course of or
    in connection with our provision of the goods and services requested by you; or
    (b) to third party service providers, agents and other organisations we have
    engaged to perform any of the functions with reference to the above mentioned
    purposes.

  7. 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 a contract with you)

    WITHDRAWING YOUR CONSENT
  8. 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 collecting, 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 Protection Officer at the contact details provided below.

  9. 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.

  10. 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 goods or 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 8
    above.

  11. 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.

    ACCESS TO AND CORRECTION OF PERSONAL DATA
  12. If you wish to make (a) an access request for access to a copy of the personal data
    which we hold about you or information about the ways in which we use or disclose
    your personal data, or (b) a correction request to correct or update any of your personal
    data which we hold about you, you may submit your request in writing or via email to
    our Data Protection Officer at the contact details provided below.

  13. 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.

  14. 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 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).

    PROTECTION OF PERSONAL DATA
  15. To safeguard your personal data from unauthorised access, collection, use, disclosure,
    copying, modification, disposal or similar risks, we have introduced appropriate
    administrative, physical and technical measures such as minimised collection of
    personal data, authentication and access controls (such as good password practices,
    need-to-basis for data disclosure, etc.), encryption of data, up-to-date antivirus
    protection, regular patching of operating system and other software, securely erase
    storage media in devices before disposal, and web security measures against risks.

  16. You should be aware, however, that no method of transmission over the Internet or
    method of electronic storage is completely secure. While security cannot be guaranteed,
    we strive to protect the security of your information and are constantly reviewing and
    enhancing our information security measures.

    ACCURACY OF PERSONAL DATA
  17. We generally rely on personal data provided by you (or your authorised 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.

    RETENTION OF PERSONAL DATA
  18. We may retain your personal data for as long as it is necessary to fulfil the purpose for
    which it was collected, or as required or permitted by applicable laws.

  19. 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.

    TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
  20. 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 we
    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.

    DATA PROTECTION OFFICER
  21. 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, in the following manner:
    Contact No. : +65 6459-2338
    Email Address : dpo@traxx.biz

    EFFECT OF NOTICE AND CHANGES TO NOTICE
  22. This Notice 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.
  23. We may revise this Notice 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 Notice was
    last updated. Your continued use of our services constitutes your acknowledgement
    and acceptance of such changes.