DATA PROTECTION POLICY

We, at Vance Chemicals Pte Ltd (“VCPL”), take our responsibilities under the Personal Data Protection Act 2012 (the “PDPA”) seriously. We also recognize the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data. This Data Protection Policy is designed to assist you in understanding how we collect, use and/or disclose the personal data you have provided to us, as well as to assist you in making an informed decision before providing us with any of your personal data. If you, at any time, have any queries on this policy or any other queries in relation to how we may manage, protect and/or process your personal data, please do not hesitate to contact our Data Protection Officer (the “DPO”) by phone +65 6863 0863 or email us to sales@mr-mckenic.com.

1 Introduction to the PDPA

1.1 In this Policy, “Personal Data” refers to any 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, including data in our records as may be updated from time to time. 1.2 Examples of such Personal Data you may provide to us include (depending on the nature of your interaction with us) your name, NRIC, passport or other identification number, age or birth date, mobile number(s), telephone number(s), facsimile number(s), mailing address, email address, network data and any other information relating to any individuals which you have provided us via our interaction with you.

2 Purpose for Collection, Use and Disclosure of Personal Data

2.1 Depending on your relationship with us (e.g. a customer, distributor, job applicant, employee, service provider, or other person relating to our organisation), the personal data which we collect from you may be collected, used and/or disclosed for the following purposes: 2.1.1 When you submit any forms relating to any of our products and services; 2.1.2 When you enter into any agreement or provide other documentation or information in respect of your interactions with us, or when you use our services; 2.1.3 When you interact with our staff, for example, via telephone calls, letters, face-to-face meetings, social media platforms and emails; 2.1.4 When you interact with us via any of our websites or use services on any of our websites; 2.1.5 When you request that we contact you or request that you be included in an email or other mailing list; 2.1.6 When you respond to our promotions, initiatives or to any request for additional Personal Data; 2.1.7 When your images are captured by us via CCTV cameras while you are within our premises, or via photographs or videos taken by us or our representatives when you attend events at our premises; 2.1.8 When you are contacted by, and respond to, our marketing representatives; 2.1.9 When we receive references from business partners and third parties, for example, where you have been referred by them; 2.1.10 When you engage us through any social media on the Internet and on the social media itself; 2.1.11 When we seek information from third parties about you in connection with the products and services you have applied for; and/or 2.1.12 When you submit your Personal Data to us for any other reason 2.2 If you provide us with any Personal Data relating to a third party (eg. information of your spouse, children, parents, and/or employees), by submitting such information to us, you represent and warrant to us that you have obtained the consent of the third party to provide us with their Personal Data for the respective purposes. 2.3 Generally, VCPL collects, uses and discloses your Personal Data for the following purposes: 2.3.1 responding to your queries, feedback and requests; 2.3.2 verifying your identity and processing payments; 2.3.3 managing the administrative and business operations of VCPL and complying with internal policies and procedures; 2.3.4 providing updates and other communications on developments relating to VCPL; 2.3.5 facilitating business asset transactions (which may extend to any mergers, acquisitions or asset sales) involving VCPL; 2.3.6 matching any Personal Data held which relates to you for any of the purposes listed herein; 2.3.7 preventing, detecting and investigating crime and analysing and managing commercial risks; 2.3.8 facilities management (including but not limited to maintaining the security of our premises); 2.3.9 managing the safety and security of our premises and services (including but not limited to carrying out CCTV surveillance); 2.3.10 in connection with any claims, actions or proceedings (including but not limited to drafting and reviewing documents, transaction documentation, obtaining legal advice, and facilitating dispute resolution), and/or protecting and enforcing our contractual and legal rights and obligations; 2.3.11 conducting investigations relating to disputes, billing or fraud; 2.3.12 managing and preparing reports on incidents and accidents; 2.3.13 meeting or complying with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which have jurisdiction over VCPL (including but not limited to responding to regulatory complaints, disclosing to regulatory bodies and conducting audit checks, due diligence and investigations); 2.3.14 financial reporting, regulatory reporting, management reporting, risk management, audit and record keeping purposes; 2.3.15 project management; 2.3.16 providing media announcements and responses; and/or 2.3.17 any other purpose reasonably related to the aforesaid.

3 Specific Uses for the Disclosure of Personal Date to Third Parties

3.1 We respect the confidentiality of the personal data you have provided to us. 3.2 VCPL will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, your Personal Data may be disclosed by VCPL, for the purposes listed above (where applicable), to the following entities or parties, whether they are located overseas or in Singapore: 3.3 The instances listed above at paragraph 3.2 are not intended to be exhaustive. For an exhaustive list of exceptions, you are encouraged to peruse the PDPA which is publicly available at http://statutes.agc.gov.sg

4 Request for Access, Correction and/or Withdrawal of Personal Data

4.1 You may request to access and/or correct the personal data currently in our possession or withdraw your consent for the collection, use and/or disclosure of your personal data in our possession or under our control at any time by submitting your request through the following methods: Data Protection Officer : Ms Lim Swee Cheng Telephone number : +65 6863 0863 Email address : sales@mr-mckenic.com 4.2 For a request to access personal data, we will provide you with the relevant personal data within a reasonable time from such a request being made. 4.3 For a request to correct personal data, we will process your request, including undertaking necessary verification activities, as soon as practicable after the request has been made. We will send the corrected personal data to every other organisation to which the personal data was disclosed by VCPL within a year before the date the correction was made, unless that other organisation does not need the corrected personal data for any legal or business purpose, or if you so consent, only to specific organisations to which the personal data was disclosed by us within a year before the date the correction was made. We may also be charging you a reasonable fee for the handling and processing of your requests to access and/or correct your personal data, but you will be notified in advance of such costs. 4.4 For a request to withdraw consent, we will process your request within a reasonable time from such a request for withdrawal of consent being made. Requests for withdrawal of consent may adversely impact your relationship with VCPL. We will notify you in advance of such impacts.

5 Administration and Management of Personal Data

5.1 We will take appropriate measures to keep your personal data accurate, complete and updated. 5.2 We will also take reasonable efforts to take appropriate precautions and preventive measures to ensure that your personal data is adequately protected and secured. Appropriate security arrangements will be taken to prevent any unauthorized access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your personal data. However, we cannot assume responsibility for any unauthorized use of your personal data by third parties which are wholly attributable to factors beyond our control. 5.3 We will also take reasonable efforts to ensure that the personal data in our possession or under our control is destroyed and/or anonymized as soon as it is reasonable to assume that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (ii) retention is no longer necessary for any other legal or business purposes.

6 Updates on Data Protection Policy

6.1 As part of our efforts to ensure that we properly manage, protect and process your personal data, we will be reviewing our policies, procedures and processes from time to time. 6.2 We may amend the terms of this Data Protection Policy at our absolute discretion.